Submission 392
To: Senate Community Affairs Legislation Committee
Re: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill
2026
I write to express significant concerns regarding the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 and its potential impact on Australians living with disability, their families, support networks, and the broader disability sector.
While there is broad recognition that the National Disability Insurance Scheme (NDIS) must remain financially sustainable and that measures to address fraud, exploitation, and misuse of funds are necessary, the proposed amendments risk fundamentally altering the purpose and accessibility of the Scheme. The NDIS was established as a rights-based insurance scheme designed to provide reasonable and necessary supports to people with permanent and significant disability. Any reforms must preserve this foundational principle, and the proposed reforms do the opposite of this.
Concern 1: Restrictive Eligibility Measures
The proposed changes place significant emphasis on redefining eligibility through functional capacity assessments and further clarification of permanence requirements.
Whilst functional capacity is an important consideration, there is considerable concern that the proposed framework may create barriers for individuals whose disabilities fluctuate, are episodic, or whose support needs are not adequately captured through standardised assessment processes. There is also a risk that the reliance on functional capacity assessment focuses heavily on the competence of the assessor, which is already a highlighted and accepted issue amongst therapists.
There is a significant risk that:
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Individuals with psychosocial disability, neurological conditions, rare disorders, and complex support needs may be disproportionately disadvantaged; the assessor’s knowledge and understanding becomes integral to their assessment which places significant disadvantage and potential discrimination opportunities if the assessor is not as competent as their peers.
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Standardised assessment tools may fail to account for environmental factors, cumulative disability impacts, behavioural presentations, and support requirements across multiple life domains.
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Participants may be excluded despite experiencing substantial and ongoing disability-related barriers.
The NDIS was never intended to support only those with the most visible or measurable impairments. A narrow interpretation of functional capacity risks undermining equitable access and creating unintended discrimination against certain disability cohorts.
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Concern 2: Cost Reduction Appears to be Driving Policy Outcomes
Public statements surrounding the proposed reforms have repeatedly referenced expenditure reduction targets and participant number reductions.
This creates a perception that fiscal outcomes are driving legislative reform rather than participant need, evidence-based practice, or disability rights. This is further evidenced by the proposal in the Bill allowing the Minister full power to arbitrarily cut funding by a given percentage to an entire funding category, regardless of the impacts this will have on individuals.
Cost containment should be an outcome of effective system design, not the primary objective of disability policy.
Legislation that is primarily designed to reduce participant numbers or funding expenditure risks:
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Shifting costs onto already strained state systems
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Increasing pressure on public health services.
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Increasing homelessness, crisis interventions, mental health admissions, and justice system involvement.
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Reducing participant independence and community inclusion. This is also compounded by the lack of information that has been released regarding the alternative support systems that will be “replacing” the supports currently funded by the NDIS.
The long-term social and economic costs of withdrawing supports may ultimately exceed any projected savings.
Concern 3: Increased Administrative Burden and Reduced Flexibility
The proposed amendments may significantly increase reassessment requirements, evidentiary burdens, and administrative complexity for participants.
Many participants already experience extensive delays, repeated requests for evidence, and significant emotional distress associated with planning and review processes. There has been inconsistent information published by the NDIS regarding the length of plans and their ability to “roll over” or be “autoextended”. Recent plans have been 5 years in length which has been a relief to families who are tired of regular interactions with the NDIS, often acknowledged to be an exhausting and stressful process. The proposed Bill amendment restricts all plans to be 12 months in length, with no opportunity for rollover or extension. This increases not only the mental load for participants and their families, but places additional reporting requirements in place, which in turn cost more and result is less funding available for therapy.
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These proposed changes will result in:
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Delayed access to essential supports.
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Increased administrative costs for both participants and government.
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Greater reliance on advocacy, legal services, and Administrative Review Tribunal proceedings. This is already being evidenced as the ART had 76% increase in lodged NDIS appeals in 2025 compared to 2024, and since October 2025, when the last major reform of the NDIS occurred, there have been 7935 active cases lodged with the ART. This is only going to increase, costing the NDIS millions in legal costs. The proposed legislative changes risk increasing the tribunal workloads, which in turn increase the NDIS’ financial spending in legal fees (increased from $10.1 million in 2019 to approximately $75.4million in 2025.)
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Reduced participant confidence in the Scheme; already evidenced by the above ART lodgment increase.
Rather than reducing administrative burden, the proposed amendments will increase it, and increase the financial impact on the NDIS, which negates the reasoning behind the proposed changes.
Concern 4: Impact on Participants with Complex Support Needs
Many participants require intensive coordination between multiple service systems, including health, housing, justice, mental health, education, and disability services.
The proposed amendments appear to strengthen the “most appropriate funding body” considerations and place greater emphasis on alternative service systems, none of which have bene identified as yet.
While intergovernmental responsibility is important, the reality is that many mainstream systems remain under-resourced, inaccessible, or unable to provide the level of support required by people with significant disability. This was once of the reasons for the inception of the NDIS, and there is no evidence of improvement in this area.
Without substantial investment in foundational and mainstream supports prior to implementation, participants risk falling into service gaps where no system assumes responsibility.
Participants with Complex Support Needs already face significantly more challenges given their required interaction with the above multiple service systems. Their behaviours and support needs are not linear, thus fluctuate and rely on flexible supports. The proposed amendments do not take any of this into account with no consideration given to individual circumstances prior to funding cuts. One participant has recently stated that these arbitrary cuts are so potentially harmful that the Government may as well “give people with disability the Green Needle”. This comment alone should show the severe mental impact that these potential reforms are having on the people it is going to directly affect.
21 Teddington Road, Burswood WA 6100 P: +61 8 9279 9888 E: admin@roshana.com.auSubmission 392
The result will be increased risk, reduced safety, and poorer outcomes for some of the Scheme’s most vulnerable participants, which contradicts the reason the Scheme was created.
Concern 5: Lack of Meaningful Co-Design
The disability community has consistently advocated that reforms to the NDIS must be developed through genuine co-design with people with disability.
Many stakeholders have expressed concern that reforms of this scale are progressing without sufficient consultation regarding:
- Assessment methodologies.
- Eligibility thresholds.
- Transition arrangements.
- Safeguards for existing participants.
- Appeals and review pathways. Meaningful reform requires the lived experience of people with disability to be central to policy development.
Concern 6: Impact on Support Coordination and Participant Safeguards
The proposed reforms raise significant concerns regarding the future role, scope, and accessibility of Support Coordination within the NDIS.
Support Coordination plays a critical role in assisting participants to understand their plans, engage providers, navigate service systems, manage risk, build capacity, and implement complex support arrangements. This is particularly important for participants with psychosocial disability, cognitive impairment, intellectual disability, acquired brain injury, and complex behavioural presentations.
Reducing access to Support Coordination or limiting its availability may result in:
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Increased plan underutilisation.
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Reduced participant capacity to exercise genuine choice and control.
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Greater vulnerability to service disengagement, exploitation, abuse, neglect, and financial misuse.
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Increased crisis presentations requiring intervention by health, housing, child protection, justice, and emergency services.
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Delayed implementation of therapeutic recommendations and Home & Living supports. The assumption that participants can independently navigate increasingly complex NDIS processes without appropriate support is inconsistent with the realities experienced by many participants with significant disability. It also refutes the very reason that Support Coordination was created in the inception of NDIS.
21 Teddington Road, Burswood WA 6100 P: +61 8 9279 9888 E: admin@roshana.com.au
Submission 392
Rather than reducing investment in Support Coordination, reforms should recognise it as a preventative measure that improves plan implementation, reduces crises, and supports better long term outcomes.
Tendering Support Coordination to the largest providers is a substantial risk to participant support, personalised service delivery and tailored, person centred care, all of which were the foundational pillars of NDIS. Larger providers should have the capacity to merge smaller independent providers within their company, allowing participants to retain their support coordinators and their personal support; many support coordinators have built long standing professional relationships with the people they support and the level of trust there should not be ignored or undermined.
Concern 7: Risks to Home and Living Outcomes
The proposed reforms may have unintended consequences for participants requiring Supported
Independent Living (SIL), Individualised Living Options (ILO), Specialist Disability Accommodation
(SDA), and other Home and Living supports.
Many participants requiring Home and Living supports have highly complex needs that involve significant functional impairment, behavioural support requirements, risks to safety, and extensive multidisciplinary evidence.
In practice, Home and Living applications already experience lengthy delays, multiple evidence requests, and inconsistent decision-making processes. Evidence is either ignored or misunderstood, and the Home and Living team are not consistent nor justified in the decisions they make, yet are able to quote the Act as a blanket reason for rejection of approval. With the current system already being very difficualt and stressful for participants to navigate and gain the supports they desperately need, the propese reforms will serve only to exacerbate an already recognised problem.
Further restrictions to eligibility or funding as a result of these proposed changes will result in:
- Participants remaining in unsuitable family homes.
- Increased hospital discharge delays.
- Increased homelessness and housing instability.
- Placement breakdowns.
- Escalation of restrictive practices.
- Increased carer burnout and family breakdown. Home and Living supports should be recognised as preventative investments that reduce reliance on more costly crisis responses and institutional settings. Yet this is currently not the case, and will be even less recognised under the proposed reforms. This is terrifying, not only for those who currently have Home and Living decisions, but for participants in desperate need of Home and living support to survive.
The NDIS should continue to support evidence-based Home and Living pathways that promote
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participant autonomy, dignity, and community inclusion. They should not arbitrarily be allowed to cut funding for no evidenced reason, with no case by case management taken into account.
Concern 8: Disproportionate Impact on Psychosocial Disability
Participants with psychosocial disability may be disproportionately affected by the proposed amendments.
Unlike many physical disabilities, psychosocial disability often presents with fluctuating symptoms, periods of relative stability, and episodic deterioration. Functional impacts can vary significantly over time and may not be adequately captured through standardised assessments conducted at a single point in time. The standardised assemssments may also not be fully tailored to Psycosocial disability; it is a well acknowledged fact that NDIS do not take psychosocial disability into as much account as observable physical disability, especially when considering comorbidities and funding for therapeutic supports.
Many participants with psychosocial disability require ongoing support to:
- Maintain housing.
- Engage with healthcare services.
- Build and maintain relationships.
- Participate in employment and education.
- Manage daily living activities.
- Prevent deterioration that may result in hospitalisation or crisis intervention. Restrictive eligibility measures risk excluding participants whose disability-related impairments are substantial but not easily measurable through conventional assessment frameworks. Any reforms must ensure that psychosocial disability remains appropriately recognised within the Scheme and that assessment processes accurately reflect the fluctuating nature of these disabilities.
Concern 9: Risks Associated with Standardised Functional Assessments
The proposed reliance on standardised assessment tools raises concerns regarding validity, reliability, and fairness.
Whilst assessments can assist decision-making, they should not replace professional judgement or comprehensive evidence from treating professionals.
A single assessment process may fail to adequately consider:
- Environmental barriers.
- Behavioural complexity.
- Cumulative impacts across life domains.
- Cultural considerations.
- Trauma history. 21 Teddington Road, Burswood WA 6100 P: +61 8 9279 9888 E: admin@roshana.com.au
Submission 392
- Communication barriers.
- Informal support availability.
- Risks associated with deterioration. There is also a risk that standardised assessment outcomes may be interpreted as definitive measures of disability despite known limitations.
Assessment tools should inform decision-making rather than determine access or funding outcomes in isolation.
Participants must retain the ability to provide broader evidence regarding their functional capacity and support requirements.
Concern 10: Cost-Shifting to Other Government Systems
One of the greatest risks associated with restrictive NDIS reforms is the transfer of costs to other government-funded systems.
Where disability supports are reduced or withdrawn, participant needs do not disappear. Instead, those needs are often transferred to:
- Public hospitals.
- Emergency departments.
- Mental health services.
- Housing and homelessness systems.
- Child protection services.
- Aged care services.
- Police and justice systems.
- State-funded disability programs. Evidence consistently demonstrates that early intervention and community-based disability supports are significantly more cost-effective than crisis-driven responses.
Reducing access to disability supports may generate short-term budget savings within the NDIS while creating substantially higher costs elsewhere across government.
Policy decisions should therefore be evaluated based on whole-of-government costs rather than NDIS expenditure alone.
Concern 11: Erosion of Choice and Control
Choice and control are foundational principles of the NDIS and underpin the Scheme’s participant centred approach.
21 Teddington Road, Burswood WA 6100 P: +61 8 9279 9888 E: admin@roshana.com.auSubmission 392
There is concern that increasing prescription around funded supports, tighter funding boundaries, and more restrictive interpretations of reasonable and necessary supports may reduce participants’ ability to tailor supports to their individual circumstances.
A more prescriptive system risks returning to the block-funded service models that existed prior to the NDIS, where participants had limited autonomy and reduced influence over decisions affecting their lives.
The success of the NDIS has been built upon recognising that disability is highly individual and that support arrangements must be flexible enough to respond to differing needs and goals.
Reforms should strengthen, rather than diminish, participant choice and control.
Recommendations
It is recommended that the Committee:
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Delay implementation of any restrictive eligibility measures until comprehensive co-design and independent evaluation has occurred.
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Publish the assessment methodologies, evidence base, and validation studies supporting any proposed functional capacity assessment framework.
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Ensure participants with psychosocial disability, fluctuating conditions, neurological conditions, and complex behavioural support needs are protected from unintended exclusion resulting in regression, decreased functionality and increased mental health concerns.
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Establish independent oversight mechanisms to monitor the impact of reforms on participant outcomes.
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Guarantee that participants currently accessing the Scheme are not disadvantaged through retrospective application of new eligibility criteria.
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Invest in foundational supports and state-based disability services before reducing access to the NDIS. Ensure these are sustainable, disability codesigned and transparent.
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The Committee should undertake a comprehensive independent impact assessment of the proposed amendments before implementation, including modelling of impacts on:
- Participants with complex support needs.
- Psychosocial disability cohorts.
- Home and Living outcomes.
- Support Coordination access.
- Tribunal appeal volumes.
- Hospital admissions. 21 Teddington Road, Burswood WA 6100 P: +61 8 9279 9888 E: admin@roshana.com.au
Submission 392
- Housing and homelessness services.
- Carer wellbeing.
- Whole-of-government expenditure. Such an assessment is essential to ensure that reforms intended to improve sustainability do not unintentionally undermine participant outcomes or increase costs elsewhere within the broader service system.
Conclusion
The NDIS is one of Australia’s most significant social reforms and has transformed the lives of hundreds of thousands of Australians living with disability.
While improvements to sustainability, governance, and fraud prevention are necessary, these objectives must not come at the expense of access, equity, participant choice and control, or the fundamental rights of people with disability.
The proposed amendments would create barriers for individuals who rely upon the NDIS to live safely, participate in their communities, maintain relationships, access employment and education, and avoid more costly crisis-based interventions. The amendments are not person centered, do not consider induvial need and the unique situation that every person with a disability experiences.
Any reform must preserve the original intent of the Scheme: supporting Australians with permanent and significant disability to live ordinary and meaningful lives with dignity, autonomy, and opportunity. The current proposals do the exact opposite, and will result in exclusion, isolation, increased dependence on hospitals, increased justice involvement and, terrifyingly, increases in self harm and suicide due to lack of support and feeling undervalued and not worth their governments support.
Respectfully submitted,
Rebecca Wood
NDIS Manager
Head Office
21 Teddington Road, Burswood WA 6100 P: +61 8 9279 9888 E: admin@roshana.com.auSubmission 392
21 Teddington Road, Burswood WA 6100 P: +61 8 9279 9888 E: admin@roshana.com.au